Revised Development Strategy

Object

Representation ID: 55388

Received: 26/07/2013

Respondent: Home Builders Federation Ltd

Housing Numbers: Since the revocation of West Midlands RSS the overall proposed housing provision across the region is estimated to have fallen by 8%. RDS para 1.3 states the Council is awaiting the outcome of a new SHMA, therefore important that the Council does not assume that strategic pressures do not exist. The "What Homes Where?" toolkit suggests a higher figure of 15,557 new households over the plan period. When this higher number of households is converted into a likely dwelling requirement, the provision of only 12,300 new homes would seem to be a substantial under estimation of housing needs. The Council may wish to consider using the "How Many Homes / What Homes Where" toolkit.

RDS suggests an over reliance on the 2011-based statistics and the Council should be cautioned against any attempts to use these latest figures to justify low housing requirements in the Local Plan. The Council should refer to the Cambridge Centre for Housing & Planning Research (CCHPR) report "Choice of Assumptions in Forecasting Housing Requirements Methodological Notes" dated March 2013, which advises against the downward revision of projected population / household figures.

At this time, the Council's main evidence source is the Warwick DC SHMA Final Report dated March 2012 which is not an NPPF compliant SHMA.

Housing supply: NPPF emphasises that local planning authorities should continue to demonstrate a 5 year housing land supply, which is to be supplemented by an additional buffer of 5% to ensure choice and competition in the land market or where there has been a record of consistent under delivery of housing an additional buffer of 20%. RDS states that at present there is not a 5 year supply of land for housing within the District as required by the NPPF. Without a 5 year housing land supply, the Council will have to identify and release more development land in a wider range of locations or formulate a strategy to bring forward sites from later in the plan period sooner. The Plan needs to demonstrate maximum flexibility to ensure delivery of an objectively assessed housing need in accordance with NPPF.

The consultation makes no reference to the provision of 5% or 20% buffer in its land supply, which the Council must address to be compliant with Paragraph 47 of the NPPF.

Viability: To be compliant with the NPPF, development should not be subject to such a scale of obligations and policy burdens that viability is threatened. Council will need to justify the infrastructure requirements via the preparation of an Infrastructure Delivery Plan. Unfortunately there are a number of concerns about the assumptions used in the Council's viability assessment, which do not correlate with the recommendations of the Harman Report. As a consequence there is potentially a significant under estimation of actual costs of particular concern are build costs, costs for Code for Sustainable Homes, cost for Lifetime Homes standards, finance costs, professional fees, sales & marketing costs and S 106 contribution payments.

In Section 5 of the RDS 40% affordable housing provision with at least 25% of housing built to Lifetime Homes standards is proposed. However even with the under estimated cost inputs this proposal is not justified by the viability assessments, which demonstrate that at the Baseline Market Position no development was viable at 40% affordable housing provision.

On Sustainable Urban Extension sites (66% of the proposed land supply) at the Baseline Market Position only between 0 - 25% affordable housing provision was possible. Recommendation in paragraph 10.8 of the Affordable Housing Viability Assessment should be considered by the Council. Council should be mindful that it is inappropriate to set unachievable policy obligations.

The Council should cross reference The Affordable Housing Viability Assessment Final Report against the Community Infrastructure Levy Viability Study Final Report dated June 2013 to identify any inconsistencies between the two reports. Paragraphs 6.18 - 6.27 of the CIL Viability Study are very confusing. It is not obvious the amount of affordable housing provision achievable given the proposed CIL charges for each of the three residential CIL charging zones. The Council must clarify the proposed CIL charges and its affordable housing policy. Then the viability testing of both requirements should be synchronised.

Object

Representation ID: 60354

Received: 26/07/2013

Respondent: Home Builders Federation Ltd

Plan Period is confusing, refers to a 15 year plan period but the plan commencement and end dates of 2011 - 2029 are 18 years apart, the Council should clarify the plan period.

Duty to co-operate: Warwick DC has 4 neighbouring authorities. At examination the Council will have to demonstrate co-operation within the wider context of neighbouring authorities.